The introduction of extraneous information into the jury room has been recognized by courts as posing a potential threat to the due process rights of litigants and the Sixth Amendment rights of criminal defendants. At the same time, however, courts encourage jurors to use their prior experience and common sense as a means of analyzing the evidence at trial. Expert jurors occupy a space at the intersection of these two poles. By virtue of their own personal expertise, they pose a distinct risk of bringing in the sort of information other jurors are prohibited from seeking out by simply using personal experience to analyze the evidence and theories at trial. Given the modern-day jury, which unlike its historical counterpart is limited to the evidence at trial, how should courts handle the risks expert jurors pose?

This Note examines that question. It first situates the jury in its historical context and discusses the problem of extraneous information. It then details the present case law on when a juror’s use of personal expertise introduces extraneous information. Finally, it suggests alternative solutions to the problem expert jurors can pose.